Immigration consultant Karim is preparing an Express Entry application for Josephine who has worked in Canada as

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Immigration consultant Karim is preparing an Express Entry application for Josephine who has worked in Canada as an accountant on a work permit for 18 months. She now qualifies for PR in the Canadian Experience Class. Karim is collecting the details of her work history as required for the application. He emphasizes that her work history back ten years must be complete, detailed and accurate. Josephine informs him that the work history she provided on her earlier work permit form was not as detailed, in fact was not really the same - and there were probably some errors on it. She filled out her own work permit form and didn't pay that much attention.   

Karim advises Josephine they can include a brief explanation of this issue now, to pre-emptively address possible questions that might be raised by the IRCC.  He recommends they just admit the work history information on the PR application is not the same as she provided on her earlier work permit and apologize for any errors. She agrees.

Nevertheless, three months later, a procedural fairness (PF) letter arrives from IRCC alleging that Josephine may have misrepresented material facts in her current application or her previous temporary application. If so, this could render her inadmissible for five years for misrepresentation under s 40 of IRPA.  She has 30 days to respond.

Karim is not sure how to respond to the procedural fairness letter. He does some research and writes a letter to the best of his ability explaining that these were innocent mistakes and citing some case law and policy on misrepresentation. 

Despite Karim's efforts, the application is refused on the grounds of misrepresentation. Now Karim is considering his next step. He does not have experience with misrepresentation and is contemplating finding someone with more expertise to help.   